Disclosure of Other Support

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Policy Number:
UW-4031
Responsible Office:
Research and Sponsored Programs

University Policy

Rationale/​Purpose:

This policy is created to:

  • Comply with the provisions of federal law, the Office of Management and Budget’s regulations, including 2 CFR 200, the Uniform Guidance, and other relevant sponsor requirements.
  • Establish expectations with faculty and staff about other support information.
  • Promote the best possible alignment between faculty and staff activity and funding sources and, in so doing, enhance work at UW–Madison.

As one of the nation’s leading research institutions, UW–Madison recognizes the importance of providing good stewardship of institutional and extramural funds. The university’s stewardship responsibilities include complying with federal requirements for disclosing other support (also known as current and pending support). Other support may include active, pending, or previous sources of support for a faculty member’s research and other sponsored activities.

Sponsoring agencies request information on other support as part of the proposal process, often prior to the issuance of an award, or as part of the annual progress report process. Sponsors use the information to ensure that scientific, budgetary, or commitment overlap do not occur. The requirement for disclosure is in place to demonstrate that:

  • The funding agency is not providing funds for work that is already supported by another source;
  • The faculty member has sufficient time available to conduct the work for which funds are being requested; and
  • Only funds necessary to conduct the approved project are included in the award.

Additionally, there is current interest in the federal government on undue foreign influence on the U.S. research enterprise, and federal sponsors have emphasized that appropriate disclosures must be made as part of other support documents.

Scope:

All faculty and staff who engage in or propose to engage in sponsored projects; all federal and nonfederal sponsored projects

Policy:
  1. It is the policy of UW–Madison that all researchers who engage in sponsored projects will comply with federal law, university policies, and sponsoring agency requirements regarding the provision of information on other support documents.
  2. UW–Madison requires that every disclosure to an external funding agency of a researcher’s active, pending, or previous sources of support for research and other sponsored activities be current, accurate, and complete to the best of the researcher’s knowledge.
    1. This requirement applies regardless of the source of support, whether or not UW– Madison is the recipient of the support. For example, if a researcher with a joint appointment is listed as a principal investigator on an award to another institution, that must be disclosed in other support.
    2. The requirement for disclosure applies at the time of proposal submission, prior to the award of support, as part of the annual progress report, and at any subsequent time the agency determines appropriate during the term of the award.
  3. It is the investigator’s responsibility to ensure the accuracy of other support documents for the project team, in accord with the application guidelines or the sponsor’s instructions.
  4. False, fictitious, or fraudulent statements or claims (including intentional omissions) in violation of this policy may result in university and sponsor administrative, civil, or criminal penalties.
Procedure:

Further information about the University’s procedures for this policy are available on RSP’s website.

Related UW–Madison Documents, Web Pages, or Other Resources:

Federal Agency Guidance Regarding Disclosures of Other Support

External References:

Policy Administration

Approval Authority:
Associate Vice Chancellor for Research Administration, Director Research and Sponsored Programs
Policy Manager:
Associate Vice Chancellor for Research Administration
Contact:
Associate Vice Chancellor for Research Administration -- Mark Sweet, MASWEET@RSP.WISC.EDU, (608) 265-9252
Policy & Planning Analyst -- Jennifer Rodis, RODIS@RSP.WISC.EDU, (608) 890-2538
Effective Date:
08-14-2019
Date Issued:
08-14-2019
Retrieved:
11-21-2024 04:05:21